37 



Just briefly on what happened in Virginia in the early 1990's. 

 The Park Service after your hearing in 1990, finally took action to 

 rescue, to try to rescue, Shenandoah from the disastrous impacts 

 of air pollution. 



Unfortunately, the PSD process has been rife with political inter- 

 ference at that time from Bush administration political appointees. 

 In the case of the Old Dominion Electric Cooperative Plant, the 

 Park Service was considering an appeal of the permit in the spring 

 of 1991. 



However, pressure from the utility industry and the applicants 

 persuaded the Secretary of the Interior and his staff to direct the 

 Park Service not to appeal the permit. When NPS failed to protect 

 Shenandoah from the proposed ODEC plant, we appealed the 

 State-issued air permit seeking EPA's help. 



EPA had the opportunity at that time to reduce the NO x emis- 

 sions from Clover, the ODEC plant, by 8,000 tons per year. The 

 ODEC opinion failed to do that, and also let stand Virginia's policy 

 of not looking at the impact on the park of new sources located 

 more than 100 kilometers away. 



This leaves the Park Service in the untenable position of having 

 the burden to quantify an adverse impact on the park but not hav- 

 ing any applicant-provided modeling to indicate the level of emis- 

 sions that will reach the park. EPA needs to issue guidance that 

 will force States to require increment modeling from all PSD 

 sources within 200 kilometers of the class I areas and large sources 

 even beyond 200 kilometers. 



I would note, and it is covered in my written testimony, that the 

 Park Service was also prohibited as was the Forest Service from fil- 

 ing an appeal of the Hadson-Buena Vista permit. We did file a per- 

 mit appeal that we carried forward. 



Finally, where we are is that EPA is going to have to take the 

 lead on these issues and cannot rely on regional voluntary commis- 

 sions. EPA needs to provide these commissions the tools to in fact 

 reduce emissions. 



Thank you. 



Mr. Synar. Thank you, Mr. Carr. 



[The prepared statement of Mr. Carr follows:] 



